Title
Regalado vs. De la Pena
Case
G.R. No. 202448
Decision Date
Dec 13, 2017
Petitioner occupied respondents' land without consent; RTC lacked jurisdiction due to unalleged property value, voiding all proceedings.

Case Digest (G.R. No. 202448)
Expanded Legal Reasoning Model

Facts:

  • Parties and Property
    • Respondents Emma, Jesusa, Johnny, Johanna, Jose, Jessica, and Jaime Antonio de la Pena are registered owners of two parcels (Lot No. 138-D TCT No. T-103187 and Lot No. 138-S TCT No. T-103189) totaling 44 hectares in Murcia, Negros Occidental.
    • Petitioner Joseph O. Regalado allegedly entered the subject properties in 1994 without respondents’ knowledge or consent, planted sugar cane, and did not pay rent.
  • Pre-Complaint Events
    • In the 1995-1996 crop year respondents discovered petitioner’s occupation and orally demanded he vacate; petitioner refused.
    • Parties underwent barangay conciliation before the Lupon Tagapamayapa of Cansilayan on September 29, 1997, which issued a Certificate to File Action.
  • Trial Court Proceedings
    • On March 9, 1998 respondents filed a Complaint for recovery of possession and damages with injunction before RTC Bacolod, Branch 42.
    • Petitioner countered that respondents had executed waivers of their undivided shares in favor of Jaime, who in turn waived his interest in favor of petitioner, and moved to dismiss for lack of jurisdiction, arguing the action was ejectment and should be in the MTC.
    • Respondents replied that the waivers were conditioned on payment of a ₱6.7 million loan with RPB and PNB, which neither Jaime nor petitioner paid, rendering the waivers void; they further argued RTC jurisdiction based on the timing of the demand.
    • On July 31, 2000 the RTC denied the motion to dismiss, presuming the assessed value of the property exceeded ₱20,000.
  • Decisions Below
    • On January 20, 2009 the RTC ordered petitioner to return possession of the lands and pay ₱50,000 as attorney’s fees, finding no proof of consideration for the purported waiver.
    • On May 28, 2012 the Court of Appeals affirmed the RTC decision, rejecting respondents’ claim for damages and petitioner’s claim of consideration; it upheld RTC jurisdiction based on stipulation and presumption of value.

Issues:

  • Jurisdiction
    • Did the RTC have jurisdiction over the subject matter of the case?
  • Merits
    • Did the Court of Appeals err in ruling that petitioner must return possession of the properties to respondents?
    • Should petitioner be awarded damages?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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